- 11 - failed to provide evidence upon which we can make a rational estimate. See Vanicek v. Commissioner, supra. We sustain respondent’s determination on this issue. 3. Legal and Professional Fees Petitioners deducted $73,232 in 1990, $42,228 in 1991, and $33,733 in 1993 for legal fees. Generally, legal fees may be deductible under section 162(a) if they are connected to a taxpayer’s trade or business. See Guill v. Commissioner, 112 T.C. 325, 328-329 (1999); Davis v. Commissioner, T.C. Memo. 1999- 250. Petitioner generally testified that he incurred more than $32,000 in legal fees in connection with his consulting work for the Federal Reserve Board. Petitioner did not provide any additional details regarding the legal fees, such as the dates, attorneys retained, and how the legal expenses were incurred in his trade or business.9 Petitioner also did not produce documents at trial to establish that he incurred these expenses. We are unable to estimate an amount for legal fees because petitioner failed to provide evidence upon which we can make a rational estimate. See Vanicek v. Commissioner, supra. We hold for respondent on this issue. 9 Petitioner’s testimony as to the legal fees was so vague that we do not know the year or years in which petitioner incurred the $32,000.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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